Regulation of Custodial Practices Under the Investment Advisers Act of 1940: Rule 206(4)-2
In-depth outline of Advisers Act Custody Rule requirements, exceptions, reporting, and enforcement cases.
November 17, 2025
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2025 Sample Examination Letter – Boston
This is a sample SEC routine examination letter from Boston that also includes questions on cybersecurity, investments not held by a qualified custodian, and an acquisition.
January 01, 2025
March 2024 Sample Examination Letter – Chicago
This is a sample SEC routine examination letter from Chicago that also includes questions on investments not held by a qualified custodian.
March 27, 2024
IAA Submits Additional Comments on SEC’s Safeguarding Proposal
The IAA submitted a comment letter urging the SEC to make additional changes to its proposed rule relating to the safeguarding of advisory client assets.
October 30, 2023
IAA Letter to SEC on Safeguarding Advisory Client Assets Proposal
IAA comment letter urging the SEC to make substantial changes to its proposed rule relating to the Safeguarding of Advisory Client Assets.
May 08, 2023
The IAA joined 11 other trade associations to submit a letter to the SEC requesting an extension of the comment period for the Safeguarding Client Assets Proposal.
March 03, 2023
Non-DVP Settlement and the Custody Rule
Responding to an SEC letter to the IAA seeking feedback, we submitted a joint letter to SEC staff explaining why transactions that settle non DVP should not be subject to the Custody Rule.
May 13, 2021